The Pilot Port EST. 2024 · KFXE
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Dry leases (§91.23).

Drafting, executing, and operating clean dry leases under FAR §91.23 truth-in-leasing.

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§91.23 is the regulation operators most commonly muddle when lending out an airplane. We don't. We draft the lease, file with FAA Aircraft Registration in Oklahoma City, notify the FSDO 48 hours before first flight, and carry a copy in the aircraft per the rule.

Standard pattern: lessee provides the pilot, hourly Hobbs-based dry rate, block prepayment, MX cost pass-through, insurance verification before key handover.

Engagements are scoped per client. Aircraft, lessee, and lease terms remain confidential.

What's included

Frequently asked

Common questions.

What is the difference between a wet lease and a dry lease?
In a wet lease the lessor provides the aircraft and the crew. In a dry lease the lessor provides only the aircraft; the lessee provides the pilot and operational control. Wet leases are generally a Part 135 activity. Dry leases done correctly under §91.23 keep the operation on the Part 91 side of the line.
What is FAR §91.23 truth-in-leasing?
§91.23 is the FAA regulation that governs leases of large civil aircraft. It requires a written lease with specific language about operational control, a copy of the lease in the aircraft, notification to the FSDO 48 hours before the first flight, and a filing with the FAA Aircraft Registration Branch in Oklahoma City. Skipping any of those steps puts the operation at regulatory risk.
Do I need a Part 135 certificate to charge for flying my own aircraft?
If you are providing both the aircraft and the pilot for compensation, the FAA generally considers that a commercial operation that requires a Part 135 certificate. A clean dry lease, where the lessee provides the pilot and operational control, is the structure used to stay on the Part 91 side. The distinction is fact-specific; we draft the lease, not the legal opinion.
Who has operational control under a dry lease?
The lessee. Operational control means the authority to initiate, conduct, and terminate the flight. Under a correctly structured §91.23 dry lease, the lessee selects the pilot, decides whether to fly, and accepts the operational responsibility. If the lessor controls those decisions, the FAA may view the arrangement as a sham lease.
How long does it take to put a dry lease in place?
A clean lease can be drafted, signed, filed in Oklahoma City, and FSDO-notified inside a week. The 48-hour FSDO notification before the first flight is the gating item; everything else can run in parallel. Insurance verification before key handover is non-negotiable.
Does The Pilot Port act as the lessor or the lessee?
Neither by default. We draft and operate the lease structure between an aircraft-owning entity and a flying entity. We can supply a contract pilot to the lessee under a separate pilot services scope, which preserves the §91.23 boundary.
Can a dry lease cover multiple lessees on the same aircraft?
Yes, an owner can dry lease the same aircraft to multiple lessees through separate lease agreements, each filed and FSDO-notified. The structure has to be clean per lessee; you cannot share one lease across multiple operators.

What problem are you trying to solve?

Each engagement is scoped per client. Email and we'll respond.

fly@thepilotport.com